DEQ-CFW_00065359

ROY COOPER
Governor
F.
Air Quality
ENVIRONMENTAL QUALITY
May 25, 2017
Ms. Hope Walters
E, H & S Competency Consultant
Kuraray America Inc. - Elizabethtown
22824 NC Hwy 87 West
Fayetteville, NC 28306
MICHAEL S. REGAN
Secretary
MICHAEL A. ABRACZINSKAS
Director
SUBJECT: Permit Applicability Determination — Permit Not Required
Applicability Determination Application No. 3058
Kuraray America Inc. — Elizabethtown
357 Executive Drive
Elizabethtown, NC 28337, Bladen County
Dear Ms. Walters:
The Division of Air Quality received your application on May 22, 2017 requesting that this Office
determine whether an Air Quality Permit is necessary for the Imbibing Process.
In light of the information provided, personnel of the Division of Air Quality have reviewed your
letter relative to applicability to Air Quality Permits, and our determinations are listed as follows:
The potential emissions, without controls, of VOC and HAP (Methanol) from the Imbibing
Process, as submitted in your applicability request and follow-up email correspondence of
May 23, 2017, will be less than 5 tons per year each.
2. Therefore, the process is exempt from permitting requirements under 15A NCAC 02Q
.0102(h)(5).
Therefore, this Office has determined that an Air Quality Permit is not required for the Imbibing
Process. It should be noted that this exemption from the permitting requirement does not exempt
Kuraray America Inc. - Elizabethtown from complying with the applicable emission control
standards.
State of North Carolina I Environmental Quality I Air Quality
Fayetteville Regional Office I Systel Building, 225 Green Street, Suite 714 1 Fayetteville, NC 28301-5094
910 433 3300 T 1910 485 7467 F
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Ms. Walters
May 25, 2017
Page 2
It should be noted that any emissions resulting for the Imbibing Process must be accounted for on all
facility wide emission summaries.
Furthermore, should you decide to modify the process such that the result is an increase of
emissions of air pollutants including toxic air pollutants, an Air Quality Permit may be required
and Kuraray America Inc. - Elizabethtown should submit a permit application to this Office prior
to such actions.
It should also be noted that future Regulations including Federal Maximum Achievable Control
Technology (MACT) for hazardous air pollutant (HAP) may be promulgated and adopted by the
Division which apply to this type of manufacturing facility. If so Kuraray America Inc. -
Elizabethtown may be required to apply for an Air Quality Permit for this equipment at that date.
This exemption from the permitting requirement is based upon your statement that equipment has
been and will be operated under the threshold levels as outlined in the Regulation. Please be
advised that the operation of any air pollution emission sources which results in emissions in
excess of the threshold levels without an Air Quality Permit is a violation of 15A NCAC 2Q.0101,
"Required Air Quality Permits." If this facility is required to obtain an Air Quality Permit for this
equipment in the future because of required emissions, each day of operation of the emission
sources without an Air Quality Permit represents a separate violation. Such violations may be
subject to enforcement action pursuant to NCGS 143-215.114A.
If you have any questions, with reference to the above matter, please do not hesitate to contact
Gregory Reeves at 910-433-3373.
Steven F. Vozzo, Regional Supervisor
Division of Air Quality, NCDEQ
cc: Fayetteville Regional Office
DEQ-CFW 00065360